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FCA Compliance for UK Cryptoasset Providers 2026: Complete Guide

Published 8 August 2026 · Last reviewed 17 October 2026 · Buckingham Capital Consulting
Contents
  1. UK crypto compliance in 2026: two regimes now, a third from October 2027
  2. UK crypto compliance requirements at a glance
  3. MLR registration remains a live requirement
  4. Registration does not convert into authorisation
  5. The regulated perimeter from October 2027
  6. What changes by business model
  7. Crypto financial promotions are already regulated
  8. Consumer Duty for authorised crypto firms
  9. Conduct of business rules
  10. Rules for trading platforms and intermediaries
  11. CASS 17: the crypto custody regime
  12. Third-party custody and outsourcing
  13. CRYPTOPRU: capital and liquidity
  14. Stablecoin issuers
  15. Senior managers and individual accountability
  16. Operational resilience
  17. Admissions, disclosures and market abuse
  18. Complaints and redress
  19. Financial crime under the new regime
  20. International groups and UK presence
  21. Governance, reporting and notifications after authorisation
  22. Compliance calendar for 2026 and 2027
  23. Frequently asked questions
Key takeaways
  • UK crypto firms comply now with MLR registration and the financial promotion rules in force since 8 October 2023, and with full FSMA rules from 25 October 2027.
  • The FCA application window is open from 30 September 2026 to 28 February 2027; registration does not convert into authorisation.
  • CRYPTOPRU sets capital from £75,000 for arranging to £750,000 for dealing as principal, plus K-factors such as 0.04% of client cryptoassets safeguarded.
  • CASS 17 requires client cryptoassets to be held on trust, with entitlement records, reconciliations and private key controls.
  • The Consumer Duty, SM&CR, operational resilience (FG26/6) and the CRYPTO 4 market abuse regime all apply to authorised crypto firms.

UK crypto compliance in 2026: two regimes now, a third from October 2027

A UK cryptoasset provider in 2026 complies with two frameworks that are already in force and prepares for a third. Exchanges and custodian wallet providers are registered with the Financial Conduct Authority (FCA) and supervised for anti-money laundering under the Money Laundering Regulations 2017 (the MLRs). Every promotion of cryptoassets to UK consumers must follow the financial promotion rules that have applied since 8 October 2023.

From 25 October 2027, the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 bring trading platforms, dealers, brokers, custodians, UK stablecoin issuers and staking providers into full FCA authorisation. The FCA published its final rules for that regime on 30 June 2026, and its application window is open now, from 30 September 2026 to 28 February 2027.

This guide sets out what each framework requires, what changes at commencement and what a compliance team should be doing now. The authorisation process itself is covered in our UK crypto licence guide.

UK crypto compliance requirements at a glance

The table shows each compliance area, its position today and its position once the new regime commences.

AreaApplies nowFrom 25 October 2027
Money Laundering RegulationsFCA registration and AML supervisionContinue alongside FSMA authorisation
Financial promotionsIn force since 8 October 2023Continue, with authorised firms approving their own promotions
FSMA authorisationWindow open 30 September 2026 to 28 February 2027Required for each in-scope activity
Consumer DutyApplies to authorised firms onlyApplies to relevant retail crypto activity (FG26/5)
Conduct of business (COBS)Promotion rules in COBS 4Wider conduct rules by activity
Custody (CASS 17)Not yet in force for cryptoTrust, records, reconciliation and key controls
Prudential (COREPRU and CRYPTOPRU)No capital rules under the MLRsCapital from £75,000 to £750,000 plus K-factors
SM&CRNot applicable to registered-only firmsSenior managers approved; conduct rules for staff
Operational resilienceGeneral expectationsImportant business services and tolerances (FG26/6)
Admissions and market abuseNot applicableCRYPTO 3 disclosures and CRYPTO 4 market abuse rules
Complaints (DISP)Firm's own proceduresFCA complaint handling rules by activity

Two points shape every transition plan. The final rules apply to firms granted permission on or after 25 October 2027, so the rules are known now and applications are assessed against them. And MLR registration does not convert into FSMA authorisation: every registered firm with in-scope activity must apply.

MLR registration remains a live requirement

Until commencement, a cryptoasset exchange provider or custodian wallet provider carrying on business in the UK must be registered with the FCA before it starts trading and must keep complying with the MLRs. The FCA's supervision of registered firms is detailed. It covers ownership, business model, source of funds, customer risk, transaction monitoring and the capability of management.

What a registered firm must maintain

  • a business-wide risk assessment and a customer risk methodology that reflect the firm's actual customers, products, delivery channels and countries;
  • customer due diligence, with enhanced due diligence for higher-risk customers and politically exposed persons;
  • ongoing monitoring and transaction monitoring that cover both on-chain and fiat flows;
  • the cryptoasset travel rule in Part 7A of the MLRs, which since 1 September 2023 has required originator and beneficiary information to travel with cryptoasset transfers;
  • sanctions screening and suspicious activity reporting to the National Crime Agency;
  • a nominated officer and money laundering reporting officer (MLRO) with the authority and resources to act;
  • notifications to the FCA of changes to management, beneficial owners and business activities.

The FCA reviews an FSMA application against what it already knows from supervision. Open AML findings, weak transaction monitoring or past promotion issues should be resolved before the firm applies, and the application should show how the existing control framework has been extended to the wider FSMA standards.

Registration does not convert into authorisation

The FCA has confirmed there will be no automatic conversion and no fast-track for registered firms. A registered firm that wants to keep carrying on in-scope activity applies for the relevant Part 4A permissions, or varies its permission if it is already FSMA-authorised.

The transition work has four parts: map the new regulated activities against what the firm does; decide the permissions and the legal entity that will hold them; check that governance and resources are adequate for an authorised firm; and build the conduct, prudential, client asset and operational frameworks the final rules require. The business plan, forecasts, policies and controls must describe one coherent operating model.

Timing matters. A firm that applies by 28 February 2027 and is still awaiting a decision on 25 October 2027 can continue its business under the saving provision. A firm that applies later and is not authorised by commencement can only perform existing contracts, for up to two years.

The regulated perimeter from October 2027

The new regime covers seven activities: operating a qualifying cryptoasset trading platform, dealing as principal, dealing as agent, arranging deals, safeguarding qualifying cryptoassets, qualifying cryptoasset staking and issuing a qualifying stablecoin in the UK. The FCA's final rules also apply specific conduct requirements to cryptoasset lending and borrowing.

One platform often needs several permissions. An exchange that holds customer assets operates a platform and safeguards; a broker that executes against its own inventory deals as principal; a staking service that holds customer tokens safeguards and arranges staking. The analysis follows the customer journey and the movement of assets, not the commercial label, and it records which group entity carries on each step.

Overseas firms serving UK consumers are within scope even when they operate from abroad, because the 2026 Regulations treat many activities with UK consumers as carried on in the UK. The structure should be settled before compliance frameworks are written for it.

What changes by business model

The compliance build depends on the business. The table shows the main additions each type of provider makes beyond its MLR framework.

Business modelMain additions from October 2027
Exchange with custodyPlatform rules, CASS 17 custody, admissions and market abuse surveillance, £150,000 PMR plus K-factors
Broker or OTC desk dealing as principalBest execution, pre-trade disclosure, conflicts, £750,000 PMR
Broker routing orders as agentOrder handling, UK venue requirement, disclosures, £75,000 PMR
Custodian wallet providerCASS 17 trust, records, reconciliations and key controls, K-RCS at 0.04%
Staking providerStaking disclosures and consent, custody where tokens are held, K-CCS at 0.04%
UK stablecoin issuerFull backing, redemption at par, CASS 16, £350,000 PMR and K-SII at 1%
Payment firm or EMI adding cryptoA separate FSMA permission for the crypto activity, alongside existing payments obligations

Every model adds the Consumer Duty for retail customers, SM&CR, operational resilience, complaint handling and the overall risk assessment. The cost and time of the build are driven mostly by custody and trading, where the operational evidence is most detailed.

Crypto financial promotions are already regulated

Since 8 October 2023, promotions of qualifying cryptoassets to UK consumers have been inside the financial promotion regime. A promotion must be communicated by an FCA-authorised firm, approved by one under section 21 of FSMA, or made by an MLR-registered cryptoasset business using the registered firm exemption. Overseas firms are caught where their promotions reach UK consumers, whether or not they are registered in the UK.

What the promotion rules require

  • a prescribed risk warning, clear and prominent, on every promotion;
  • a 24-hour cooling-off period for first-time investors with the firm;
  • client categorisation and an appropriateness assessment before a consumer can invest;
  • no incentives to invest, such as refer-a-friend bonuses or new-joiner rewards;
  • promotions that are fair, clear and not misleading, including on social media and through influencers.

A working promotions framework covers websites, apps, social media, influencers, affiliates and referral campaigns, with approval records and version control for every live promotion. From commencement, a firm authorised for cryptoasset activities approves its own promotions, and an unauthorised firm can no longer rely on a section 21 approver for in-scope activity. The FCA has said section 21 approvers should not approve promotions for anyone carrying on regulated activity without permission.

Consumer Duty for authorised crypto firms

The FCA finalised the application of the Consumer Duty to regulated cryptoasset activities in PS26/13 on 30 June 2026, with non-Handbook guidance in FG26/5. Authorised firms serving retail customers must deliver good outcomes in four areas: products and services, price and value, consumer understanding and consumer support.

Crypto raises particular questions under each outcome. Prices are volatile, the technology is complex, transfers cannot be reversed and the economics of staking or lending can be hard to follow. The FCA expects firms to address these at product design, through the target market, the customer journey and the support model, rather than relying on risk warnings alone.

Where the Duty bites in practice

  • Products and services: a defined target market for each product, and journeys that do not present high-risk products as ordinary savings.
  • Price and value: spreads, fees and staking or lending returns assessed against the benefits customers receive.
  • Understanding: communications tested with customers, including explanations of custody, staking and loss scenarios.
  • Support: clear routes for lost access, account restrictions, fraud, mistaken transfers and withdrawals, with service levels monitored.

Outcome monitoring should show whether particular products or customer groups, including vulnerable customers, receive worse outcomes, and the board should review it each year. Our guide to Consumer Duty compliance sets out the annual board report and monitoring framework.

Conduct of business rules

PS26/13 applies relevant parts of the Conduct of Business Sourcebook (COBS) to authorised cryptoasset firms, and PS26/11 adds activity-specific rules in the CRYPTO sourcebook for trading platforms, intermediaries, lending and borrowing, staking and custody. The obligations depend on the activity and the customer, and they are considerably more structured than anything under MLR registration.

Conduct risk sits in order handling, execution, conflicts of interest, pricing, disclosures and product design. A trading platform focuses on fair access and trading rules; a broker on best execution and order handling; a custodian on disclosures and asset protection. Firms using algorithms or automated execution should be able to explain how those systems produce customer outcomes and how errors are detected and corrected.

Policies should map to the firm's future permissions rather than form a generic manual. Compliance monitoring should test both the detailed COBS rule and the customer outcome, because the Consumer Duty works alongside the specific conduct rules and does not replace them.

Rules for trading platforms and intermediaries

PS26/11 sets activity-specific conduct rules in the CRYPTO sourcebook. They bring crypto trading close to the standards that apply to traditional trading venues and brokers, adapted to how crypto markets operate.

Trading platforms

  • access rules that are non-discriminatory and based on objective criteria, with non-discretionary rules for executing orders;
  • a principal dealing desk in the same entity may not use the platform to execute its own trades, so the platform remains a risk-neutral venue; credit exposure beyond settlement risk needs a separate legal entity;
  • matched principal trading is permitted subject to conditions, in line with multilateral trading facility rules;
  • retail customers may only access tokens admitted with a compliant disclosure document, except UK-issued qualifying stablecoins;
  • trades are published within one minute of execution, and platforms with average revenue of £10 million or more over three years publish the best five bids and offers;
  • systems and controls to prevent disorderly markets, and operational resilience requirements under CRYPTO 6.

Brokers and dealers

  • best execution: sufficient steps to obtain the best possible result for clients, supported by periodic post-trade analysis rather than trade-by-trade checks;
  • price checks against at least three reliable prices from UK-authorised venues where available, giving priority to UK platform prices;
  • orders for UK retail clients executed on UK-authorised venues, and principal dealers not sourcing liquidity mainly from an affiliated unauthorised platform;
  • disclosure of whether the firm acts as principal or agent before execution, and a firm price, its validity and any fees for principal quotes;
  • prompt, fair handling of client orders, functional separation of proprietary trading from client execution, and personal account dealing rules similar to COBS 11.7.

The FCA has said payment for order flow is unlikely to meet the best execution, conflicts and inducement rules for retail or professional clients. It also intends to consult on extending the deadline for the UK execution venue requirement to January 2028.

Lending, borrowing and staking

PS26/11 confirms retail protections for cryptoasset lending, borrowing and staking, with targeted refinements to the collateral and auto-staking rules. Firms offering these services should design disclosures, consent and loss allocation into the product, and show in the application how customers understand what happens to their assets and returns.

CASS 17: the crypto custody regime

Firms that safeguard qualifying cryptoassets for customers come under CASS 17, set out in PS26/11. It is a significant step beyond MLR registration, which covers custody only from an anti-money laundering perspective.

What CASS 17 covers

  • holding client cryptoassets on trust, separate from the firm's own assets;
  • records of each customer's entitlement and reconciliations against the assets actually held on-chain and with third parties;
  • controls over the means of access, such as private keys, multi-party computation shares and recovery processes;
  • selection and oversight of third-party custodians;
  • investigation, escalation and resolution of any shortfall or discrepancy.

Custody architecture is both a legal and a technical design. Wallet structures, omnibus arrangements, key management, recovery processes and sub-custody must match the trust and record-keeping framework. Reconciliation breaks must be investigated, evidenced and escalated, never corrected by an unexplained ledger adjustment.

The FCA is not applying CASS 17 to the custody of relevant specified investment cryptoassets (tokenised securities) at this stage; CASS 6 applies to those. CASS 7 applies to client money that arises from safeguarding client cryptoassets.

Third-party custody and outsourcing

An authorised firm can use a third-party custodian, but it remains responsible for the assets it has undertaken to safeguard. Arranging for another firm to safeguard client cryptoassets is itself within the safeguarding activity.

Due diligence on a custodian should cover its regulatory status, financial strength, security, operational capability, jurisdiction, insolvency protections and any use of sub-custodians. The contract should support the customer trust structure that the UK rules require. For custody chains outside the UK, the firm should establish how client assets would be treated if the provider became insolvent or access was disrupted, rather than infer it from the provider's reputation.

Oversight continues after appointment. The firm should track the custodian's financial and operational position, test access and recovery, and keep an exit plan that can be executed.

CRYPTOPRU: capital and liquidity

The prudential regime sits in two new sourcebooks: COREPRU, which sets the core framework, and CRYPTOPRU, which adds the crypto-specific requirements. A firm must hold own funds at least equal to the highest of its permanent minimum requirement (PMR), its fixed overheads requirement (FOR) and its K-factor requirement. The FOR is based on the previous year's audited expenditure and represents the cost of an orderly wind-down.

ActivityPermanent minimum requirement
Dealing as principal£750,000
Issuing a qualifying stablecoin£350,000
Safeguarding, operating a trading platform or staking£150,000
Dealing as agent or arranging deals£75,000

K-factors

K-factors are capital charges that grow with the volume of business. The final coefficients in PS26/12 are:

K-factorWhat it measuresCoefficient
K-RCSClient cryptoassets safeguarded0.04%
K-CCSClient cryptoassets staked0.04%
K-SIIQualifying stablecoins in issue1%
K-CCOClient cryptoasset orders0.1%
K-CTFDaily cryptoasset trading flow0.1%
K-NCPNet cryptoasset position held40% of net exposure

As the FCA's own example shows, a staking firm would need average staked client assets above £375 million before K-CCS exceeded its £150,000 PMR. Cryptoassets that cannot be admitted to a UK platform and prudently valued are deducted from capital in full. Firms must also hold liquid assets, carry out an overall risk assessment and hold more capital where that assessment identifies risks the minimum does not cover.

Forecasts should model how the requirement changes as the business grows, not only the PMR. Prudential calculations, the business plan and the financial data template must use the same assumptions.

Stablecoin issuers

A firm issuing a qualifying stablecoin in the UK needs the issuance permission and must meet the rules in PS26/10 and CRYPTO 2. Every coin in issue must be fully backed by eligible assets, redeemable at par, and described in published disclosures. The backing assets are safeguarded under CASS 16, separate from the issuer's own assets, so that holders are protected if the issuer becomes insolvent.

Issuers hold a PMR of £350,000 and the K-SII charge of 1% of average coins in issue, reduced from the 2% proposed in consultation. Liquidity supports redemptions; capital protects the business. The two are related but separate, and the application must show both.

Stablecoins used in payments raise further questions under the payment services and e-money rules. HM Treasury has brought forward amending legislation for certain payment uses of UK-issued qualifying stablecoins, and stablecoin issuers recognised as systemic by HM Treasury come under joint Bank of England and FCA supervision. Our guide to stablecoin payments regulation covers the overlap with EMI and PI licensing.

Senior managers and individual accountability

Authorised cryptoasset firms come under the Senior Managers and Certification Regime (SM&CR). Senior managers need FCA approval before they take up their roles, each has a statement of responsibilities, and staff in certified roles are assessed by the firm as fit and proper. The conduct rules apply to almost all staff.

Responsibilities should be allocated clearly across governance, financial crime, prudential risk, custody, operational resilience and customer outcomes. Boards need enough technical understanding to challenge the people and suppliers running wallet infrastructure, key management and trading systems, and regulatory, financial and technical governance should work as one.

Our guide to SM&CR in 2026 explains the approval process, responsibilities maps and certification.

Operational resilience

The FCA issued FG26/6 on cryptoasset operational resilience alongside PS26/13. Crypto firms depend on wallet infrastructure, blockchain nodes, cloud services, identity providers, market data and many third parties, and disruption can reach every customer at once.

Authorised firms identify their important business services, map the people, technology and suppliers behind each, set impact tolerances for the maximum disruption customers can bear, and test that they can stay within them. Scenarios should include crypto-specific events: compromise of a private key, chain congestion, a protocol fork or outage, loss of blockchain connectivity, the insolvency of a third-party custodian and a major cyber incident.

Outsourcing does not move responsibility. Firms should understand concentration, sub-outsourcing and exit, and keep enough internal capability to supervise their providers.

Admissions, disclosures and market abuse

PS26/9 creates two new regimes. Under CRYPTO 3, a cryptoasset admitted to a UK qualifying cryptoasset trading platform needs a qualifying cryptoasset disclosure document, and the platform carries out due diligence and applies admission standards. Under CRYPTO 4, the market abuse regime for cryptoassets prohibits insider dealing, unlawful disclosure of inside information and market manipulation.

Trading platforms and intermediaries need surveillance of orders and transactions proportionate to their activity, adapted to crypto patterns such as wash trading, spoofing and pump-and-dump schemes. Suspicious orders and transactions are reported to the FCA. Automated surveillance generates many alerts, so firms need calibrated models, trained analysts and governance that separates real concerns from ordinary market behaviour. Market abuse monitoring should connect with financial crime controls where behaviour raises wider criminal concerns.

Complaints and redress

Authorised crypto firms apply the FCA's complaint handling rules in the Dispute Resolution sourcebook (DISP) to their regulated activities. That means written procedures to receive, investigate, resolve and record complaints, and clear information to eligible complainants about referring a complaint to the Financial Ombudsman Service where the activity falls within its jurisdiction.

Customer-service tickets do not automatically meet the regulatory definition of complaint handling. Complaint data should feed Consumer Duty monitoring: recurring complaints about withdrawals, account freezes, execution, custody or fees call for root-cause analysis and, where needed, remediation or product change.

Irreversible on-chain transactions do not remove the duty to investigate. The firm examines whether its own systems, communications or controls contributed to the customer's loss, and contract terms cannot remove a responsibility the rules place on the firm.

Financial crime under the new regime

FSMA authorisation adds conduct and prudential rules and leaves the anti-money laundering, sanctions and fraud obligations in full. The MLRs continue to apply, and the FCA's financial crime expectations in SYSC apply to authorised firms.

A complete framework includes the business-wide risk assessment, customer risk methodology, due diligence, ongoing monitoring, blockchain analytics, transaction monitoring, travel rule compliance, sanctions screening and suspicious activity reporting, covering both on-chain and off-chain activity. Blockchain analytics support judgement rather than replace it: firms should understand each tool's method and limits, calibrate its thresholds and investigate alerts in context, with extra analysis for self-hosted wallets and cross-chain activity.

The travel rule deserves its own procedures. For each transfer the firm collects and sends the originator and beneficiary information required by Part 7A of the MLRs, checks the information received on incoming transfers, and decides how to handle transfers from firms in countries that have not yet implemented the rule and transfers to or from self-hosted wallets.

Financial crime controls connect with custody, trading and the Consumer Duty. A decision to restrict an account after an alert, for example, affects customer support and complaints and needs a governed process. Our guide to FCA financial crime compliance covers the full set of expectations.

International groups and UK presence

The FCA's approach to international cryptoasset firms, FG26/7, expects a firm needing authorisation to operate through a UK legal entity with real UK presence. A sufficient share of leadership and decision-making should sit in the UK, and senior managers involved in UK activities should spend adequate time here. A UK branch alone is generally not accepted, mainly because UK client asset protections may not hold if an overseas firm becomes insolvent.

Two exceptions apply. The FCA sees a case for operating a trading platform through a UK branch where it gives UK customers access to global liquidity and the home regulator offers comparable protection; a letter of good standing alone is not enough. Firms regulated by both the PRA and the FCA may also be able to use a branch, case by case.

An overseas licence, including a MiCA authorisation, does not passport into the UK. Groups should map which entity contracts with customers, controls assets, runs technology and makes regulated decisions. Intra-group outsourcing works where the UK firm retains authority, information and capability, and capital, governance, tax, contracts and technology are designed together.

Governance, reporting and notifications after authorisation

Authorisation begins continuous supervision. The board owns the compliance framework and should receive regular management information on customer outcomes, financial crime, capital and liquidity, client assets, operational incidents and complaints.

Recurring obligations

  • regulatory returns on capital, liquidity, client assets and complaints at the frequencies the FCA sets;
  • an annual Consumer Duty board report on customer outcomes;
  • an external client assets audit where the firm safeguards client cryptoassets;
  • annual periodic fees to the FCA, and levies for the Financial Ombudsman Service where it applies;
  • an overall risk assessment reviewed at least each year and after material change;
  • compliance monitoring and internal audit plans that test the controls described in the application.

Changes that need the FCA first

New controllers need FCA approval before they acquire control, new senior managers need approval before they take up their roles, and new regulated activities need a variation of permission. Material changes to outsourcing, custody arrangements or the business model are notified in advance. A firm that keeps its application documents current through the review is well placed to meet these obligations from the first day.

Compliance calendar for 2026 and 2027

PeriodPriority for compliance teams
Now to December 2026Gap assessment against the final rules; permission matrix; board-approved implementation plan
By 28 February 2027Complete FSMA application submitted on FCA Connect to qualify for the saving provision
March to September 2027Answer FCA information requests; build CASS 17, prudential reporting, SM&CR and Consumer Duty frameworks
31 July 2027Last practical date for any new MLR registration application
25 October 2027Regime commences; operate under permission, the saving provision or the transitional provision
First year after authorisationFirst Consumer Duty board report, client assets audit, regulatory returns and periodic fees

What to do now

  1. Run a structured gap assessment comparing current MLR and promotion controls with the FSMA requirements: permissions, governance, Consumer Duty, COBS, prudential rules, operational resilience, financial crime, complaints, CASS 17 and market abuse. Rank each gap by the time and change it needs.
  2. Build one target operating model and write policies for systems that exist or can be delivered, not for promises to build later.
  3. Cost the regime properly. Forecasts should include capital, staff, technology and compliance under the future rules, tested under stress.
  4. Close historic issues. Resolve open MLR findings and promotion matters before the application goes in.
  5. Apply in the window. A complete application submitted by 28 February 2027 protects the existing business through commencement.

Support for crypto gap assessments and ongoing compliance is described on our regulatory compliance page.

Frequently asked questions

What FCA rules apply to UK cryptoasset providers in 2026?

Exchanges and custodian wallet providers must be registered and supervised under the Money Laundering Regulations, and promotions to UK consumers must meet the financial promotion rules. The FSMA authorisation regime commences on 25 October 2027, and its final rules were published on 30 June 2026.

Does FCA MLR registration become a crypto licence under FSMA?

No. Registration does not convert into a Part 4A permission. Firms carrying on in-scope activity must apply, ideally inside the window that closes on 28 February 2027.

Does the Consumer Duty apply to crypto firms?

Yes, to authorised firms carrying on relevant retail cryptoasset activity. The FCA set out its approach in PS26/13 and the FG26/5 guidance.

What is CASS 17?

CASS 17 is the FCA's client asset chapter for firms safeguarding qualifying cryptoassets. It covers trust arrangements, records, reconciliations, key and access controls and third-party custodians.

What capital will FCA-authorised crypto firms need?

The permanent minimum is £75,000 for arranging and dealing as agent, £150,000 for custody, trading platforms and staking, £350,000 for stablecoin issuance and £750,000 for dealing as principal. Fixed overheads and K-factors can raise the requirement.

Can an overseas crypto firm serve UK customers through a branch?

Generally not. FG26/7 expects a UK legal entity with real UK presence; operating a trading platform through a UK branch is the main exception.

What are the UK crypto financial promotion rules?

Promotions need a lawful route, a prescribed risk warning, a 24-hour cooling-off period for first-time investors, an appropriateness assessment and no incentives to invest. They have applied since 8 October 2023.

References

  1. FCA: New regime for cryptoasset regulation
  2. FCA: Overview of the cryptoasset regime policy statements
  3. FCA PS26/12: A prudential regime for cryptoasset firms
  4. FCA PS26/11: Regulated cryptoasset activities
  5. FCA FG26/7: Approach to international cryptoasset firms
  6. FCA: Use of s.21 approvers under the new regime
  7. The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026

About Buckingham Capital Consulting

Buckingham Capital Consulting has obtained FCA authorisations since 2013 for firms including Dzing Finance and HFS (EMI), Orbital (API) and Moneliq (variation of permission), and supports cryptoasset providers with MLR compliance, financial promotions and preparation for the FSMA regime. Its gap assessments turn the FCA's final crypto rules into a costed, board-approved programme for authorisation and ongoing compliance.

Speak to an expert: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or info@buckinghamcapitalconsulting.co.uk.

This article is general information, reviewed against the regulator’s published requirements on the date shown. It is not legal advice; the regulator’s current publications take precedence.